ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG) and the Ionising Radiations Regulations 2017 (IRR17). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ADR 2019 was used during this inspection (www.unece.org).
The purpose of the inspection was to review Weatherford UK Ltds (WUK) arrangements associated with the road transport of radioactive material. ONR carried out this inspection remotely (via Skype) on 2 September 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by WUK for the safe transport of radioactive materials, including the associated arrangements for protecting workers against the effects of ionising radiations and reducing risks as low as reasonably practicable (ALARP).
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. A number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP were identified, including to dose assessment, contamination monitoring, assigning transport indices, management of special form certification and appointment of an RPA. A number of non-compliances were identified and discussed during the inspection, which included having an appropriate consent to carry out specified practices, suitable and sufficient radiation risk assessment, emergency arrangements and training in relation High Activity Sealed Sources (HASS). While there were a number of non-compliances identified, the safety significance is considered to be nominal to moderate on the basis of the low frequency of consignments and the types of packages used are of lower consequence (Type A / excepted packages) and the arrangements were not entirely absent, but rather did not meet current relevant good practice when compared against appropriate benchmarks.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for WUK to consider.
WUK demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified seven non-compliances with relevant legislation and suggested three improvements. These were all discussed during the inspection and a commitment obtained from WUK to address them.
WUK was given until 14 October 2020 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an IIS Rating of AMBER is given, due to there being some deficiencies identified within its arrangements for compliance with legal requirements. These relate to the seven areas of non-compliance identified during the inspection.
All non-compliances will be managed through ONR’s Issues Management arrangements.